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Consultation on proposed regulations under the Health Sector Payment Transparency Act, 2017

As previously reported, on December 12, 2017, the Ontario Legislature passed the Strengthening Quality and Accountability for Patients Act, 2017, which enacts or amends 10 statutes including the Health Sector Payment Transparency Act, 2017  (Transparency Act). When in force, the Transparency Act will require disclosure of financial relationships between pharmaceutical or medical device manufacturers (among other “payors”) and health care professionals (among other “recipients”). On February 21, 2018, the Ontario Ministry of Health and Long-Term Care published for consultation proposed regulations under the Transparency Act. The proposed regulations specify: what constitutes a “transfer of value” that must be reported; who qualifies as an “intermediary” or a “recipient” of a “transfer of value”; additional categories of “payors”; what thresholds and exemptions exist to the reporting requirements; the manner and frequency of reporting; and the process for correcting posted information. The consultation period ends April 6, 2018.